Privacy Policy

Plankton Technology Private Limited (“the Company/ Plankton/ We/ Us/ CIRCLES”) is committed to operating this website/app with the highest ethical standards and appropriate internal controls. Your privacy is important to us and maintaining your trust is paramount. This Privacy Policy explains how we collect, use, and disclose information about you. By using our website/app and affiliated services, you consent to the terms of our privacy policy (“Privacy Policy”) in addition to our Terms of Use. We encourage you to read this Privacy Policy regarding the collection, use, and disclosure of your information. If you are not comfortable with any of the terms or policies described in this Privacy Policy, you may choose to discontinue usage of our website/app. This Privacy Policy shall be subject to our Terms of Use available here.

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This Privacy Policy applies to the website/app that links to this Privacy Policy but does not apply to those Plankton’s affiliates’ websites that have their own privacy policy. Any capitalized terms not defined hereunder shall hold the same definition as provided under the Terms of Use.

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From time to time, we may supplement this Privacy Policy with additional information relating to a particular interaction that we may have with you.

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Collection of Personal Information

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Information you provide us

Pursuant to the services provided by us, we will ask you to provide certain information as a part of the registration process, and in the course of the interface of CIRCLES. We will collect this information through various means and in various places through the App Services, including account registration forms, contact us forms, or when you otherwise interact with us. We will ask you to provide only such information lawfully and operationally required for the App Services and necessary to be collected by us for effectively providing the same.

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Personal information we collect may be in the nature of, inter alia,

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Name

Mobile number

Email ID

Date of Birth

PAN number

Address and Pin Code

Gender

Financial information such as UPI ID, credit card or debit card or other payment instrument details;

The collection and maintenance of any such data/information shall be subject to this Privacy Policy.

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Information we collect as you access and use our services

We will also collect information relating to your use of our website/app through the use of various technologies. For example, when you visit our website/app, we may log certain information such as your IP address, browser type, mobile operating system, manufacturer and model of your mobile device, geolocation, preferred language, access time, and time spent. We will also collect information about the pages you view within our sites and other actions you take while visiting our website/app. Collecting information in this manner allows us to collect statistics about our website/app usage and effectiveness, personalize your experience whilst you are on our website/app, as well as customize our interactions with you and also assist in business development to enhance and expand the scope of the App Services.

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We also maintain some records of Users who contact us for support, for the purpose of responding to such queries and other related activities. However, we do not provide this information to any third party without your permission or utilize the same for any purposes not set out hereunder.

Information third parties provide about you

We may, on your consent, request certain third parties to provide information about you to further personalize your experience on our website/app, and provide certain services that cannot be accessed by all users of the website/app.

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Use of Personal Information

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The following paragraphs describe in more detail how we propose to use your personal information.

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Fulfilling your Transaction Request

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Any information provided by a User will be used solely for processing your transaction or for any other purposes for which you have granted access to such information to us, based on our mutual agreement/discussions/communications/correspondences. All personal information provided by you on our website/app which has been duly received and accepted by us will be used solely for the purpose of processing a transaction on the App. To enable such process, we may share information with authorized third-parties, for instance, our business partners, financial teams/institutions, or postal/government authorities involved in fulfillment of said transactions, if any. In connection with a transaction, we may also contact you as part of our customer satisfaction surveys or for market research purposes.

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Personalising your Experience on our website/app

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We may use information we collect about you to provide you with a personalised experience on our website/app, such as providing you with content in which you may be interested and making navigation on our sites easier.

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As you access and use CIRCLES, we may request access wherever applicable to your Contact for making it easy for you to invite your contacts, should you choose so.

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Providing Support

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We may use your personal information to support our activities such as notifying you of any upcoming campaigns/programmes conducted by us.

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In the course of providing such support to you, we may sometimes have incidental access to data that you have provided to us or data that is located on your system. This Privacy Policy does not apply to our access to or handling of this information; the conditions regarding the handling and processing of that data is covered by the applicable Terms of Use or other agreements between you and Plankton.

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Marketing

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Subject to your express permission to use the information as described herein, the information you provide to us, as well as the information we have collected about you whether directly or indirectly, may be used by us for marketing purposes. You may at any time choose not to receive marketing materials from us by following the unsubscribe instructions included in each e-mail you may receive, by indicating so when we call you, or by contacting us directly.

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Some of our campaigns/programmes/related events may be co-branded, that is sponsored by both the third parties and us. If you sign up for such campaigns/programmes/related events, please note that your information may also be collected by and shared with those third parties. We urge you to familiarise yourself with their privacy policies to gain an understanding of the manner in which they will handle information about you.

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Monitoring or Recording of Calls, Chats and Other Interactions

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Certain online transactions may involve you calling us or us calling you. They may also involve online chats. Please be aware that it is our general practice to monitor and in some cases record such interactions for staff training or quality assurance purposes or to retain evidence of a particular transaction or interaction.

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Use of Information in the Social Computing Environment

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We provide social computing tools on our website/app to enable online sharing and collaboration among members who have registered to use them. These include forums, wikis, blogs, and other social media platforms.

When registering to use these tools, you will be asked to provide certain personal information. Registration information that is not automatically made available to other participants as part of your profile will be subject to and protected in accordance with this Privacy Policy.

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Any other content you post, such as pictures, information, opinions, or any other type of personal information that you make available to other participants on these social platforms, is not subject to this Privacy Policy. Rather, such content is subject to the terms of use of those platforms, and any additional guidelines and privacy information provided in relation to their use. We strongly urge to refer to them to better understand yours, ours, and other parties’ rights and obligations with regard to such content. We would also like to emphasise that the content you post on any such social computing platforms may be made available to others inside and outside our website/app.

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Protect the Rights and Property of Plankton and Others

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As required by law, at times we might be required to disclose your personal information to relevant authorities. In some cases, when we believe that such disclosure is necessary to protect our rights, or the rights of others, or to comply with a judicial proceeding, court order, or legal process served on our website/app we would share such information.

In some cases, Plankton may use vendors or suppliers located in various countries to collect, use, analyse, and otherwise process information on its behalf. It is Plankton’s practice to require such vendors or suppliers to handle information in a manner consistent with Plankton’s policies.

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We may disclose information that identifies you at an individual level and which we have collected on our website/app, to other non-Plankton entities that are not acting as our suppliers, such as our business partners. Except as described in this Privacy Policy, we will only do so with your prior consent. For the sake of clarity, Plankton does not sell or lease such information.

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Where, pursuant to strategic or other business reasons, Plankton decides to sell, buy, merge, or otherwise reorganise businesses in some countries. Such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers. It is Plankton’s practice to seek appropriate protection for information in these types of transactions.

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Opt-Out

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We provide all Users with the opportunity to opt-out of receiving non-essential (promotional, marketing-related) communications from us on behalf of our partners, and from us in general, after setting up an account. If you want to remove your contact information from all our lists and newsletters, please click on the unsubscribe button on the emailers or send an email request to support@circlesway.com.

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Cookies

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We use data collection devices such as “cookies”, etc. on certain parts of the App to help analyse the App Services, user interaction with the App, measure promotional effectiveness, and promote trust and safety. For the sake of clarity, “cookies” are small files placed on your device hard-drive/storage that assist us in providing the App Services. Please be informed that Plankton

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offers certain features via the App that are only available through the use of a “cookie”. You are always free to decline our cookies if your device permits.

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Information Security and Accuracy

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We intend to protect your personal information and to maintain its accuracy as confirmed by you. Plankton implements reasonable physical, administrative, and technical safeguards to help us protect your personal information from unauthorised access, use, and disclosure. For example, when you make payments initiated through CIRCLES but carried on by parties such as other payment gateways, wallets etc. we just share your UPI ID and depend on other parties for security, consistency and reliability of payments.

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Online Advertising

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Plankton does not deliver third party online advertisements on the website/app but we advertise our activities and organizational goals on other websites/apps. We may collaborate with other website/app operators as well as network advertisers to do so. We request you to read and understand such concerned third party privacy policies to understand their practices relating to advertising, including what type of information they may collect about your internet usage. Plankton does not provide any information relating to your usage of the website/app to such website operators or network advertisers.

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Links to third-party websites/apps

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Plankton website/app may contain links to third party websites/apps that are not affiliated with Plankton. Plankton is not responsible for the privacy practices or the content of those other websites, or for any acts/ omissions by such third parties in the course of your transaction with them.

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Notices

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Any dispute over privacy is subject to this Privacy Policy and our Terms of Use, including limitations on damages, resolution of disputes, and application of the laws of India.

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Changes to Privacy Policy

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Plankton reserves the right to change this policy, including material changes from time to time. Any changes shall be effective immediately upon the posting of the revised Privacy Policy. We encourage you to periodically review this page for latest information on our privacy practices.

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Privacy Questions and Access

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If you have questions, concerns, or suggestions regarding our Privacy Policy, we can be reached using the contact information on our “Contact Us” page or at support@circlesway.com.

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In certain cases, you may have the ability to view or edit your personal information online. In the event your information is not accessible online and you wish to obtain a copy of particular information you provided to Plankton, or if you become aware the information is incorrect and you would like us to correct it, please contact us immediately.

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Before Plankton is able to provide you with any information or correct any inaccuracies, however, we may ask you to verify your identity and to provide other details to help us to respond to your request. We will contact you within 30 days of your request.

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Security and Responsible Disclosure

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We at Plankton are committed about our customer's data and privacy. We blend security at multiple steps within our products with state of the art technology to ensure our systems maintain strong security measures.

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If you are a security enthusiast or a researcher and you have found a possible security vulnerability on Plankton products, we encourage you to report the issue to us responsibly.

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You could submit a bug report to us at support@circlesway.com with detailed steps required to reproduce the vulnerability.

We shall put best of our efforts to investigate and fix the legitimate issues in a reasonable time frame, meanwhile, requesting you not to publicly disclose it. Additionally, if you have suggestions on how we could improve our security systems to make it more robust and safe for all users, you can share those with us at support@circlesway.com